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Privacy Policy

 Effective Date: September 8th, 2023 

SNPJ (“we”, “us”, or “our”) owns and administers life insurance and annuity products. This Privacy Policy describes how SNPJ collects, uses, and discloses personal information about individuals (“you” or “your”) including: 

  • Policyholders and their beneficiaries; 
  • Users of our website, SNPJ.org, and any other websites or other services we operate which display this Privacy Policy (collectively, our “Sites”); 
  • Individuals who are referred to us; and 
  • Other people we interact with in conducting our business, including events we sponsor or host. 

Table of Contents

  • Personal information and how we collect it
  • Types of personal information we collect and share
  • How we use personal information
  • When we share personal information
  • Online data collection and how you can restrict online data collection
  • Protection of personal information
  • How long we retain personal information
  • Links to social media and third-party websites
  • Information about minors
  • Changes to this Privacy Policy
  • Communications from us
  • How to contact us
  • Information for California Residents

 Personal Information and How We Collect It 

We use the term “personal information” in this Privacy Policy to refer to information that identifies, relates to, describes, or is reasonably capable of being associated, directly or indirectly, with an individual. The term personal information does not include information that has been anonymized or aggregated so that that it no longer identifies you. 

We may obtain personal information from or about you in ways including: 

  • Forms or requests you submit to us our Sites;
  • When you set up and access an account with us;
  • The agreements, forms, and other documents you complete, sign, and submit to us;
  • Information provided by your medical or healthcare provider;
  • Information provided by your insurance broker or agent;
  • Other communications with SNPJ; 
  • Information collected using cookies and other internet technologies when you visit our Sites and your account portal as described in the section titled “Online Data Collection and How You Can Restrict Online Data Collection”; and
  • Credit reporting agencies. 

Types of Personal Information We Collect

The personal information that we collect about you depend on your interaction with the company. Specific types of information may include: 

  • Name;
  • Date of birth;
  • Home address;
  • Telephone number;
  • Information about beneficiaries;
  • Payment account number and related information;
  • Social Security number or Federal Tax ID;
  • Emergency contact list information that may include others;
  • Policy claims history and claims information
  • Health insurance information (if applicable to your policy or application); and
  • Information related to Services provided to you.

How We Use Personal Information

We may use your personal information to: 

  • Service your policy by processing claims, payments, changes, and policy renewals;
  • Determine your eligibility for our products and services;
  • Respond to your questions and communicate with you;
  • Administer our business, financial, and information technology operations;
  • Analyze aggregated data about past claims and other metrics to plan for future financial needs;
  • Manage, analyze and protect the security, performance, and functioning of our Sites;
  • Support our core business activities by managing our contractual relations, protecting our business interests, enforcing our policies, and complying with applicable law, and taking other actions to detect and prevent illegal or fraudulent activities;
  • Manage risks to the rights, privacy, property and safety of our business, policyholders, beneficiaries, and employees;
  • Comply with valid legal process and respond to appropriate governmental requests; and
  • Other purposes specifically disclosed to you at the time we may ask you to provide personal information. 

When We Share Personal Information

Your personal information may be accessible or disclosed for business purposes to the categories of third parties described below. We do not, and do not intend to, sell your personal information for any purpose. We also do not share your personal information for cross-context behavioral advertising purposes, or for purposes unrelated to our business without allowing you to “opt-out” or “opt-in.” 

Business services providers and partners. We engage third parties to support various administrative operations, including maintaining your account portal, and for professional services. 

Legal process and enforcement. We may disclose personal information to third parties to: enforce our agreements and rights; enforce the Terms of Use; comply with legal requirements; investigate, respond to and resolve claims or complaints; and respond to law enforcement, legal process, or a request for cooperation by a government entity. 

Business transaction parties. We reserve the right to disclose or transfer your personal information, subject to appropriate confidentiality safeguards, in connection with a business transaction involving us. 

Online Data Collection and How You Can Restrict Online Data Collection 

In this Privacy Policy we use the term “cookies” to refer to cookies, pixels, SDKs, JavaScript, device identifiers, and similar technologies that we (or third parties) may place on your web browser when you visit our Sites. We do not use third party tracking cookies for purposes of online advertising. 

Data collected using cookies. We may use cookies to support some of the functionality and features of our Sites. The types of data collected when you visit our Sites or use your account portal may include, for example: 

  • Identification data: Internet Protocol (IP) addresses, your account portal, and advertising and cookie identifiers;
  • Device and connection data: network and connection information including, for example, your internet service provider (ISP), device, application, domain name, browser type and version, plug-in type and version, operating system, language and time zone settings;
  • Usage metrics: usage rates, technical data (including occurrences of errors, diagnostic reports, settings preferences, backup information), content interactions (including website you visited before our Sites, date and time of your visit, pages you viewed, keywords you searched), and browsing history (including clickstreams and page navigation, URLs, timestamps, content viewed or searched for, page response times, and page interactions); and
  • Location information: general location information derived from your IP address or mobile device ID or more specific geolocation information with your consent. 

Restricting online data collection. You can restrict how cookies are used to track and log data about your visits to our Sites and other websites using settings on your web browser or device to manage how your personal information and preferences are stored. If you restrict the use of cookies some of the services on our Sites may not be fully functional. For more information, please visit www.allaboutcookies.org

Protection of Personal Information

We take commercially reasonable precautions to safeguard the personal information we collect, and we take measures to require third parties with whom we share personal information to use reasonable precautions to safeguard such information. Although we strive to protect your personal information in our control, we cannot completely guarantee the security of personal information you transmit electronically through our Sites, by e-mail, or in other ways. You are responsible for maintaining the confidentiality of your password. Please immediately notify us if you suspect or know of any unauthorized use of your account or breach of security, including loss, theft, or unauthorized disclosure of your password. 

SSN Protection Policy

We value your trust, and we are committed to the responsible protection of your Social Security number (“SSN”). This notice applies to any SSN that we collect in the course of our business. We protect the confidentiality of SSNs, including by maintaining manual and electronic security procedures to guard against unauthorized access to SSNs. We also limit access to SSNs, including by only granting access to SSNs to our employees who use that information to perform their job-related duties. In addition, we do not disclose SSNs to third parties, except where required or permitted by law. 

If you have any concern that your interaction with us is no longer secure (for example, if you are concerned that the security of any account you might have with us has been compromised), you should immediately notify us of the problem at the contact information provided below. 

How Long We Retain Personal Information

Policyholders should be aware that life insurance and annuity policies often remain in effect for many years and we will retain your personal information as necessary or appropriate to administer the policy, comply with our legal obligations, resolve any disputes, and enforce our agreements. To determine the appropriate retention period for personal information, we consider the purposes for which the information was collected, the nature of the information, any contractual relationship that may govern the retention of the data, and our legal or regulatory obligations. Based on those considerations, we will delete, remove personal information, or anonymize the information in accordance with applicable law. 

Links to Social Media and Third-Party Websites 

Privacy practices of social media and third-party websites. Our Sites may contain links to social media platforms and other websites. If you use those links to access another internet location, you will leave the SNPJ Sites and this Privacy Policy will not apply to your use and personal information you provide at those third-party locations. The personal information you provide will be collected by the third-party website operator and controlled by its privacy policy. Links we provide on the Sites to other internet locations are provided only as a convenience, and the inclusion of such links does not imply endorsement of the linked location or any security or data collection practices associated with those other websites. We encourage you to read the legal and privacy notices posted at those locations. We have no responsibility or liability for your access or use of, and the data collection and use practices of, third party platforms or websites. 

Social media. SNPJ may maintain a presence on social media platforms including Facebook and Instagram. If you choose to “Like,” “Follow,” or take any similar action on a social media platform, you are providing your consent to receive information updates, including solicitations, from SNPJ by means of that platform. To stop receiving this information from SNPJ on a social media site, you must follow the procedure established by the website. 

Information About Minors

Our Site not intended for access and use by persons under the age of 18 (except in the case of legal residents of certain states where the legal age of majority is greater than 18 years of age, who then must meet the state’s legal age of majority). Except with respect to policy beneficiary matters, we do not intentionally collect personal information from individuals who we have reason to believe are under the age of 18. If you become aware of any personal information we have collected from individuals under age 18, please contact us as explained in the section titled “How to Contact Us”. 

Changes to This Privacy Policy 

We may make periodic changes to this Privacy Policy and post the effective date at the top of this page or by other means as necessary. Your continued use of our Sites and Services constitutes your agreement to the most current version of the Privacy Policy. 

If you are a policyholder, you will also receive a copy at the start of our business relationship with you and periodically thereafter as required by law. 

By continuing to use the Sites following such changes, you will be deemed to have agreed to such changes. If you do not agree with any or all of the terms of our Privacy Policy as in effect at any time, you should not continue to use the Sites. 

Communications From Us

You can opt-out of email messages by following the “unsubscribe” instructions in these messages. If you opt-out we may still send you messages regarding transactions and other matters related to our ongoing business relationship with you. 

How to Contact Us 

If you have any questions about this Privacy Policy or our privacy practices, please contact us at: 

Information for California Residents 

Categories of personal information we collect and share:

The personal information about you that we collect includes information within the below categories of data, depending on your interaction with the company. These categories also represent the categories of personal information that we have collected over the past 12 months. Note that the categories listed below refer to the categories of personal information as defined under the CCPA. Inclusion of a category in the list below indicates only that, depending on the services and products we provide you, we may collect some information within that category. It does not necessarily mean that we collect all information listed in a particular category for all of our customers, or that the CCPA applies to the data (particularly in light of the CCPA’s exclusion for data regulated by the Federal Gramm-Leach-Bliley Act (GLBA), the Fair Credit Reporting Act (FCRA), and the Health Insurance Portability and Accountability Act (HIPAA)). 

For more information about third party access to your personal information, see the section titled, “When We Share Personal Information.” 

Categories of personal information collected in the past 12 monthsSpecific types of personal information collected in the past 12 monthsThird party access for business purposes
Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers. Name, postal address, email address, and telephone number 

Social security number, government-issued identification number, Tax identification number (TIN) 

Brokers/Registered Representatives (with your consent) 
Third Party Administrators 
IT and Other Service Providers 

Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, your name, signature, social security number, physical Characteristics or description, address, telephone number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Bank or other financial account numbers if used to make a premium payment or complete a transaction 

Signature
 
Insurance policy number, policy and plan type, and terms 

Birth certificate, marriage certificate, or death certificate 

User and password for account portal 

Internet protocol address, mobile device identifier obtained from online usage data 

Brokers/Registered Representatives (with your consent) 

Third Party Administrators 

IT and Other Service Providers 

Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. Billing and payment history 

Credit reports 

Policy forms 

Brokers/Registered Representatives (with your consent) 

Third Party Administrators 

Policy claims history and claims information 

Other transactions with SNPJ 

IT and Other Service Providers 

Characteristics of protected classifications under California or federal law, including familial status, disability, sex, national origin, religion, color, race, sexual orientation, gender identity and gender expression, marital status, veteran status, medical condition, ancestry, source of income, age, or genetic information. Age, date of birth, sex, gender, marital status, citizenship 

Medical or disability information (if applicable to your policy or application) 

Health insurance information (if applicable to your policy or application) 

Brokers/Registered Representatives (with your consent) 

Third Party Administrators 

IT and Other Service Providers 

Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding the consumer’s interaction with an Internet Web site, application, or advertisement. Interactions with our Site and the Annuities Logon page Website analytics services 

Sensitive personal information. In addition to the categories of information above, we may also collect the following categories of sensitive personal information: 

Categories of sensitive personal information collected in the past 12 months Specific types of personal information collected in the past 12 months Third party access for business purposes 
Social security, driver’s license, state Identification card, or passport number. Social security number, government-issued identification number, Tax identification number (TIN) 

Brokers/Registered Representatives (with your consent) 

Third Party Administrators 

IT and Other Service Providers 

Account log-In, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account. Bank or other financial account numbers if used to make a premium payment or complete a transaction 

Username and password for account portal 

Brokers/Registered Representatives (with your consent) 

Third Party Administrators 

IT and Other Service Providers 

Personal information concerning a consumer’s sex life or sexual orientation. Sex, genderBrokers/Registered Representatives (with your consent) 

Third Party Administrators 

Health information.Medical or disability information (if applicable to your policy or application) 

Brokers/Registered Representatives (with your consent) 

Third Party Administrators 

Rights for California consumers 

If you are a resident of California, you may be entitled to the following rights: 

Right to know. California consumers have the right to request any of the following information regarding personal information collected by SNPJ about the consumer or the consumer’s household during the last twelve (12) months (“Right to Know”): 

  • Categories of personal information we collected
  • Categories of sources from which the personal information is collected
  • Business or commercial purpose for collecting or selling personal information
  • Categories of personal information sold or exchanged for value with a third party and categories of such third parties
  • Categories of personal information disclosed to a third party for a business purpose and categories of such third parties
  • Specific pieces of personal information collected about you (except for very sensitive personally identifiable information, which we will describe but not transmit) 

The process by which we verify and respond to your requests is explained below under “How to Make a Verifiable California Consumer Request” and “How We Will Respond to a California Consumer Request.” 

Right to correct. California consumers have the right to request a business correct any mistakes in personal information about the consumer that the business has collected or update their preferences regarding the collection of personal information about the consumer; the business may not be able to accommodate the consumer’s request if it believes it would violate any law or legal requirement or cause the information to be incorrect; data solely retained for data backup purposes is generally excluded. 

Right to delete. California consumers have the right to request a business delete any personal information about the consumer that the business has collected from the consumer, subject to a range of exclusions permitted by law (“Right to Delete”). For example, a business is not required to delete personal information if it is necessary to complete a transaction, is reasonably used for an ongoing business relationship, or is used internally in a lawful manner that is compatible with the context in which the consumer provided the information. 

Once we receive and verify your request, we will separately confirm your request and follow appropriate procedures to verify the identity and authority of the person submitting the request. If the Right to Delete request is confirmed and verified, we will delete (and direct our service providers to delete) the requested personal information from our records, unless an exclusion applies. If we are unable to fulfill all or part of your request, we will let you know why (for example, if we have a permitted reason to retain certain information if the identity of the requesting person cannot be verified). 

The process by which we verify and respond to your requests is explained below under “How to Make a Verifiable California Consumer Request” and “How We Will Respond to a California Consumer Request.” 

Right to limit the use of sensitive personal information. California consumers have the right to limit the use and disclosure of the sensitive personal information SNPJ collects or maintains about them, to only those purposes necessary to provide our services (but we do not use sensitive personal information for any purpose that is not necessary to provide our services). 

Opt out of the sale of personal information. California consumers have the right to direct a business not to sell their personal information to others. In the preceding twelve (12) months, SNPJ has not made sales of personal information for monetary or other consideration and has no plans to do so. We share personal information with third parties for the business purposes described in the section of the Privacy Policy titled, “When We Share Personal Information.” 

Designating an authorized agent. California consumers may designate an authorized agent to act on their behalf to submit a Right to Know or Right to Delete request, or (if applicable) a request to opt-out from the sale of their Personal Information. An authorized agent may be a natural person or a business entity registered with the Secretary of State. An authorized agent must also submit to SNPJ written proof of their authorization to act on the consumer’s behalf. 

How to make a verifiable California Consumer Request. California consumers may submit a request to exercise any of their rights described above using the following methods: 

Please note that in order for us to verify certain requests we need to verify your identity and California residency by confirming information we have on file for you, including email address, phone number, full name, address, and other personal information. If you make a request on behalf of someone else, we will need to verify your authority to make that request. We reserve the right to deny a consumer request if the identity or authority of the requesting party cannot be confirmed. 

How we respond to a California Consumer Request. We endeavor to confirm receipt of your Right to Know, Right to Correct, or Right to Delete request within ten (10) business days and may request additional information necessary to verify that you are permitted to make the request. We will respond to any verifiable consumer request within forty-five (45) calendar days of receiving it, subject to delays and exclusions permitted by law. If we require more time to respond, we will let you know the reason and the extension period in writing. We will use the email address or U.S. Postal address you provided to us when making the request. 

If we cannot comply with all or part of your request, we will explain the reasons why. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information readily from one entity to another entity. 

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request. 

Protection from discrimination. California consumers have a right not to receive discriminatory treatment by the business for exercising the privacy rights conferred by the California Consumer Privacy Act. As such, we will not discriminate against a California consumer for exercising any of the rights described in this section. This means that except as legally permitted we will not: 

  • Deny you goods or services
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties
  • Provide you a different level or quality of goods or services
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services 

California “Shine the Light” Law. If you are a California resident, California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your personal information by us to third parties for the third parties’ direct marketing purposes within the immediately preceding calendar year. We will provide you with a list of the categories of personal information disclosed and a list of the names and addresses of the third parties. Please send a request including evidence of residency in California to: 

  • E-mail:  
  • Postal Mail: 247 West Allegheny Road, Imperial, PA 15126-9774